overview

     The challenge of multiple and overlapping demands is presented by a dynamic state and local tax environment: state tax laws change frequently, many states have conflicting rules that can result in double taxation, technology is rapidly evolving and operations can inadvertently trigger tax nexus, and the states are becoming more sophisticated in their enforcement of laws. The job of a SALT specialist is to pro-actively develop return filing positions, mitigate risk, implement tax saving compliance procedures, and defend existing positions under audit.

     Stephen has provided professional services and legal guidance to clients and their financial advisors for more than 30 years. His practice offers a model of leveraged assistance and expert support to both small and mid-size public accounting firms, law firms, high net worth individuals, as well as closely held companies in management of SALT issues.

     Stephen is a graduate of New York University School of Law, Juris Doctorate, and of the University of California, Berkeley, Bachelor of Arts, History, Cum Laude. He is a member of the New York State Bar and the New York City Bar Association State & Local Tax Committee.

     Stephen J. Bercovitch is a highly regarded, practiced state and local tax attorney with both large public accounting firm and Fortune 500 corporate industry background.

     The practice offers a full range of state and local tax support and consulting, tax planning, and audit defense work. Clients include individuals, closely held corporations, as well as other professionals: tax law firms, accounting firms, and tax consultants needing cost-effective and reliable SALT expertise in state sales/use, income/franchise, and payroll taxes.

SAMPLING OF SUCCESSES

     Resolved sell-side liabilities and dealt with multistate corporate tax consequences under Section 338(h)(10) for divested CBS, Inc. lines of business in numerous large transactions, including sales of toys, musical instruments, magazines, publishing, and records divisions, saving millions of state tax dollars.

     Initiated review of $3 billion New York investment portfolio, resulting in tax savings of $2.5 million annually based on recommendation to change investments.

     Defended combined return filing position with New York State, saving closely held digital production company one million annually.

     Negotiated changes of domicile from Connecticut to Florida and from New York to Florida for high net worth individuals saving six figures annually and insulating sales of their businesses from state income taxes.

     Negotiated UBT refund of nearly $1million for investment advisory firm based on analysis of special allocation rules that their former practitioner had overlooked.

     Negotiated New York State voluntary disclosure for a construction contractor, saving six figures in sales taxes based on a limited look back period.

     Initiated New York City Unincorporated Business Tax (“UBT”) planning for music rights holder selling its portfolio of licenses.